This is a short update of the status of the federal class action lawsuit
against Union Carbide and Warren Anderson, particularly the most recent brief filed by
counsel for plaintiffs. The briefing of Carbide's "Motion to Dismiss The Amended
Complaint, Deny Class Certification and/or For Summary Judgment" is now complete and
has been filed with the court. Subsequently, Carbide's counsel - which had accepted
service of summons and complaint for Anderson - filed a separate motion on behalf of
Warren Anderson to "Dismiss the Amended Complaint, Deny Class Certification and/or
For Summary Judgment" which consisted of all of 5 pages. In response, plaintiffs'
counsel submitted the following:

1. Plaintiffs' Memorandum of Law In Opposition To Warren Anderson's
Motion To Dismiss (25 pages) reiterating and incorporating by reference all of our
arguments against Carbide plus articulating the basis for Anderson's criminal liability as
well as civil liability based on his complicity in Union Carbide's unlawful conduct.

2. An expert affidavit from Professor Iqbal Ishar, Dean of New York
University Law School's prestigious Global Law program, and an expert in Comparative
Constitutional Law who has taught the Law of Torts for 9 years at the University of Delhi,
essentially affirming that he had reviewed the affidavit of former Chief Justice Bhagwati
on issues of Indian law such as the Bhopal Act, settlement, etc. and was prepared to
swear, under penalty of perjury, that the contents of Justice Bhagwati's affidavit were
true and correct as to the matters asserted therein.

3. An expert affidavit from Professor Naomi Roht-Arriaza, an expert in
international human rights law and international environmental law as well as an associate
chairman of the American Society of International Law, affirming under penalty of perjury
that Union Carbide's and Warren Anderson's conduct amounts to a violation of the
plaintiffs' internationally guaranteed rights to life and personal security and,
therefore, constitute breaches of customary international law actionable under the Alien
Tort Claims Act. In addition to being a professor and distinguished scholar in the field
of international law, she is also a practicing lawyer who represents the 40,000 or so
victims, "disappeared" individuals and political prisoners of Chile who were
tortured, murdered and abused during Pinochet's regime in that country.

4. An expert supplemental affidavit from Professor Jon M. Van Dyke, who
is an adviser to Micronesian countries on international human rights law and a scholar who
has published over 80 articles and 5 books on the subject of public international law,
affirming under penalty of perjury that plaintiffs' have adequately stated an actionable
claim for violation of customary international law, viz. the rights to life and
security of the person, and that Defendants' conduct constitutes a crime under
international law.

5. A "Declaration of Experts On Sources of Customary International
Law" affirming that the sources and authorities cited by Plaintiffs in support of
their legal arguments are, in fact, customary international law and/or evidence of
customary international law. The Declaration was signed by the following scholars and
experts in the field of international law:

5. An expert affidavit of Professor Richard Wilson, Director of the
International Human Rights Law Clinic at the Washington College of Law at American
University and counsel to, among others, Mumia Abu Jamaal, the indigenous peoples of
Chiapas, Mexico as well as the Zapatistas, affirming that he has reviewed the Declaration
and agrees that the contents thereof are true and correct to the best of his knowledge and
citing additional authorities in support thereof.

6. An expert affidavit by Professor Chaloka Beyani, a Professor of
International Law and Human Rights at the London School of Economics and Political Science
and a Lecturer at Oxford University (Law), affirming under penalty of perjury that the
plaintiffs have stated a claim for violation of customary international law and that Union
Carbide and Anderson's conduct amounted to a breach of their rights to life and personal
security as well as a breach of the prohibition against cruel, inhuman and degrading
treatment or punishment.

7. Newspaper articles evidencing comments from Anderson that strongly
indicate his involvement in the design, operation and maintenance of the UCIL plant in
Bhopal.